MANAGING RISK ON THE DECK PLATES : IMPLEMENTING
ENTERPRISE RISK MANAGEMENT AT THE TACTICAL
LEVEL IN THE ROYAL CANADIAN NAVAL RESERVE
Commander Matthew Dalzell
JCSP 44
Exercise Solo Flight
Disclaimer
Opinions expressed remain those of the author and do not represent Department of National Defence or Canadian Forces policy. This paper may not be used without written permission.
© Her Majesty the Queen in Right of Canada, as represented by the
Minister of National Defence, 2019.
PCEMI 44
Exercice Solo Flight
Avertissement
Les opinons exprimées n’engagent que leurs auteurs et ne reflètent aucunement des politiques du Ministère de la Défense nationale ou des Forces canadiennes. Ce papier ne peut être reproduit sans autorisation écrite.
© Sa Majesté la Reine du Chef du Canada, représentée par le
ministre de la Défense nationale, 2019.
CANADIAN FORCES COLLEGE – COLLÈGE DES FORCES CANADIENNES
JCSP 44 – PCEMI 44
2017 – 2019
EXERCISE SOLO FLIGHT – EXERCICE SOLO FLIGHT
MANAGING RISK ON THE DECK PLATES:
IMPLEMENTING ENTERPRISE RISK MANAGEMENT AT THE TACTICAL
LEVEL IN THE ROYAL CANADIAN NAVAL RESERVE
By Commander Matthew Dalzell
“This paper was written by a candidate attending the Canadian Forces College in fulfilment of one of the requirements of the Course of Studies. The paper is a scholastic document, and thus contains facts and opinions, which the author alone considered appropriate and correct for the subject. It does not necessarily reflect the policy or the opinion of any agency, including the Government of Canada and the Canadian Department of National Defence. This paper may not be released, quoted or copied, except with the express permission of the Canadian Department of National Defence.”
« La présente étude a été rédigée par un stagiaire du Collège des Forces canadiennes pour satisfaire à l'une des exigences du cours. L'étude est un document qui se rapporte au cours et contient donc des faits et des opinions que seul l'auteur considère appropriés et convenables au sujet. Elle ne reflète pas nécessairement la politique ou l'opinion d'un organisme quelconque, y compris le gouvernement du Canada et le ministère de la Défense nationale du Canada. Il est défendu de diffuser, de citer ou de reproduire cette étude sans la permission expresse du ministère de la Défense nationale. »
1
MANAGING RISK ON THE DECK PLATES:
IMPLEMENTING ENTERPRISE RISK MANAGEMENT AT THE TACTICAL LEVEL
IN THE ROYAL CANADIAN NAVAL RESERVE
INTRODUCTION
Systematic approaches to managing and mitigating risk are a hallmark of modern
business practises. While they originated in the private sector, risk management processes have
been increasingly adopted by Western governments and public sector institutions over the last 20
years, starting at the enterprise-wide, strategic level and trickling down within institutions.
Enterprise risk management policies are part of strategic governance within the Department of
National Defence and the Canadian Armed Forces. However, applying enterprise risk
management policies at the operational and tactical level, such as in the Royal Canadian Naval
Reserve, is inconsistent. Implementing enterprise risk management policy at the tactical level
ensures the consistent application of policy objectives in a manner that minimizes
misinterpretation and promotes the adoption of a risk culture. Using the policy analysis model
proposed by Walt and Gilson, it can be demonstrated that the development of bottom-up
integrated risk policy is necessary for the meaningful implementation of top-down strategic
enterprise risk management in the Naval Reserve.
BACKGROUND
Enterprise and Integrated Risk Management
Risk is the uncertainty that surrounds future events based on the likelihood of a particular
event occurring and its potential impact.1 Enterprise risk management (ERM) – considered here
to be a term interchangeable with integrated risk management – first came to prominence in the 1 Canada, Treasury Board Secretariat, Framework for the Management of Risk (Ottawa: Treasury Board Secretariat, 2010) http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=19422. Accessed 24 March 2019.
2
1990s with its origins in the financial sector with systematic approaches to identify, assess and
manage risks that cut across an organization.2 Prior to this, risks were most frequently managed
in silos by separate units with little or no coordination or proactive appreciation of how decisions
to deal with risk might interact with each other or their potential strategic effects.3 By the turn of
the century, standards and practices began to be codified by national and international
organizations, most notably by the Committee of Sponsoring Organizations of the Treadway
Commission in the United States and by standards organizations in Australia, New Zealand and
Canada,4 with adoption of ERM advocated by regulators and rating agencies, among others.5
The Government of Canada first adopted ERM in 2001 with the publication of the
Integrated Risk Management Framework by the Treasury Board Secretariat.6 This policy
provided guidance for the identification and management of risk on “an aggregate basis”7 and its
incorporation into decision-making processes within organizations across government. It
included common definitions for risk, risk management and integrated risk management. A
companion document, the Integrated Risk Management Implementation Guide, was published in
2004 to assist organizations with the adoption of risk management processes such as the
development of risk registers. The policy was refreshed and updated in 2010 with the issuance of
2 P. Bromiley, M. McShane, A. Nair, E. Rustambekov, “Enterprise Risk Management: Review, Critique and Research Directions,” Long Range Planning 48 (2015): 266-267. 3 W. Ben-Amar, A. Boujenou and D. Zeghal, “The Relationship between Corporate Strategy and Enterprise Risk Management: Evidence from Canada,” Journal of Management and Strategy 5, no. 1 (2014): 3. 4 J. Fraser and B. Simkins, “The challenges of and solutions for implementing enterprise risk management,” Business Horizons, 59 (2016): 689-690. 5 Bromiley et al. 2015, 265. 6 K. Hardy, Enterprise Risk Management: A Guide for Government Professionals (San Francisco: John Wiley and Sons, 2014), 42, O’Reilly Learning/Safari Books, https://learning.oreilly.com/library/view/enterprise-risk-management/9781118911037/?ar 7 Canada, Treasury Board Secretariat, ARCHIVED – Integrated Risk Management Implementation Guide. Ottawa: Treasury Board Secretariat, no date. http://www.tbs-sct.gc.ca/pubs_pol/dcgpubs/riskmanagement/guidepr-eng.asp?format=print. Accessed 24 March 2019.
3
the Treasury Board Secretariat’s Framework for the Management of Risk8 and Guide to
Integrated Risk Management.9
This policy framework provides consistent direction and standards for ERM throughout the
Government of Canada with central agency oversight. This includes the Department of National
Defence (DND), the Canadian Armed Forces (CAF)10 and its component ‘Level 0’ and ‘Level 1’
elements. The Royal Canadian Navy (RCN) first set out an integrated risk management policy in
2012, which was amplified with a Naval Order in 2016.11 A new RCN ERM Policy was issued in
2018 aligned with Canada’s 2017 defence policy and the RCN’s five-year strategic plan.12 The
RCN ERM policy is intended to
“provide a continuous, proactive and systematic process to understand, manage and communicate risk from an organization-wide perspective in relation to the achievement of overall organization objectives….to foster a risk smart culture by ensuring personnel at all levels have regard for the management of risks in all decisions.”13
The organization of the RCN ERM governance framework is similar to corporate ERM
systems found in industry, with the Navy’s strategic governing bodies, the Naval Board and
Naval Strategic Management Board, executing the ERM oversight function that is found in a
corporate board of directors. The Deputy Commander of the RCN is mandated to act as
“Champion for Enterprise Risk Management”14 supported by the Director of Naval Strategic
Management who manages Navy ERM functions. Subordinate Formation Commanders are
expected to implement and promote ERM within their ‘Level 2’ operational organizations. 8 Treasury Board Secretariat, Framework for the Management of Risk. 9 Canada, Treasury Board Secretariat, Guide to Integrated Risk Management (Ottawa: Treasury Board Secretariat, 2010) https://www.canada.ca/en/treasury-board-secretariat/corporate/risk-management/guide-integrated-risk-management.html. Accessed 23 April 2019. 10 Department of National Defence, Defence Enterprise Risk Management Policy (Ottawa: DND, June 2018). 11 Royal Canadian Navy, Naval Order (NAVORD) 1950-1, “Integrated Risk Management”, 25 February 2016. 12 Royal Canadian Navy, Enterprise Risk Management Policy (August 2018): 2. 13 Ibid. 14 Ibid., 6
4
Finally, subordinate commanders and individual commanding officers are expected to “Adhere
with (sic) orders, directives and policies related to [ERM]…and build a risk aware culture by
promoting ERM practices within their respective areas of operations.”15
ERM’s limitations on the deck plates
While the RCN’s ERM framework is robust at the strategic level, its reach into the
organization through policy to the tactical level – to units and individual sailors - is limited,
despite its stated intent to “foster a smart risk culture [in] personnel at all levels.” This challenge
is due principally to the limitations inherent in any top-down approach, particularly where there
is limited knowledge of policy content and context, and where responsibilities and tools to
manage risk are fragmented into silos the further down one moves in an organization. It is these
silos that are regarded as the most significant impediment to implementing a successful ERM
framework.16
APPLYING POLICY ANALYSIS TO NAVAL RESERVE ERM IMPLEMENTATION
In their 1994 review of policy analysis approaches and why health reform initiatives fail,
Gil Walt and Lucy Gilson17 proposed that policy initiatives often focus too heavily on the
content of policy while giving insufficient consideration to the actors involved (e.g. policy
makers, stakeholders, concerned publics), the context into which the policy is implemented (e.g.
broader economic, cultural and political environments, previous policy initiatives and other
historical factors), and finally the process through which the policy is arrived and implemented.
15 Ibid., 7 16 J. Seago, “Governing Government Risk,” Internal Auditor, (December 2015): 48. 17 G. Walt and L. Gilson, “Reforming the health sector in developing countries: the central role of policy analysis,” Policy and Planning 9, no. 4 (1994): 353-370.
5
Their policy analysis model (Figure 1) places actors in the centre of a conceptual triangle with
policy context, content and process at each vertex. By doing so, the model encourages
consideration of these three policy elements as they mutually influence, and are influenced by,
the perspectives, motivations and choices of actors.
Actors
The central actors in this analysis are the members of the Naval Reserve, consisting of
approximately 3,800 predominantly part-time sailors and officers who are members of 24 Naval
Reserve Divisions (NRDs) located in major cities across Canada. Each NRD recruits and
conducts basic military training and supports individual on the job and readiness training to
prepare personnel to augment the RCN in standing and contingency roles. This includes training
and contingency operations involving operating minor war vessels and small boats, diving, small
Figure 1. The Walt and Gilson policy analysis triangle
6
arms, and administering public and non-public resources. The Naval Reserve is organized
geographically into four regions and is administered by Naval Reserve Headquarters in Quebec
City. With the transformation of the primary reserves in 2014, the Naval Reserve ceased to be its
own formation (a Level 2 organization) and is now officially part of Maritime Forces Pacific
with the Commander Naval Reserve reporting to the Commander of Maritime Forces Pacific in
his role as Assistant Chief of Naval Staff (Training). Known as the “One Navy” construct,18 this
reorganization aligns the Naval Reserve and Naval Reservists more squarely with the policy
requirements, expectations and accountabilities of the Regular Force Navy. Gaining and
maintaining credibility with the Regular Force Navy as a partner within One Navy is an
important reputational risk for the Naval Reserve. Naval Reservists themselves come from a
wide variety of backgrounds. Many Naval Reservists are post-secondary students or graduates
who completed the bulk of their military occupational training during periods of full-time
employment during summer breaks and now contribute on a predominantly part-time basis on
weekday evenings and occasionally weekends. The Naval Reserve is also a young organization
with a high proportion of millennials.19
Context for a Naval Reserve ERM framework
Although the Naval Reserve is subject to the strategic policy framework set in place by
the higher authorities of Defence and the RCN, it is acknowledged that a “single management
methodology applied at all levels and across all functions in Defence is not practicable.”20 Both
the Defence and RCN ERM policies are aimed primarily at the ‘Level 0’ and ‘Level 1’
organizations, with direction that ERM policy also be applied further down within the
18 Royal Canadian Navy, RCN Executive Plan – 2013 to 2017 (Ottawa: DND, 2013): 6. 19 Based on an informal survey of the demographics of the seven NRDs in the Naval Reserve’s Western Region. 20 Defence ERM Policy, 2018, 4.
7
organization – primarily to Level 2 organizations. While risk management is considered as a part
of operational planning doctrine21 and in warship command development training,22 it is still
largely confined to silos and is unknown to most Naval Reservists. More widely known, but still
isolated, are risk management policies and processes related to financial controllership,
administration, material accountability, and safety and environmental management. Many of
these are subject to rigorous oversight through mandated requirements inspections by a dedicated
staff in headquarters – including a Senior Staff Officer of Inspections and Integrated Risk
Management - or oversight by other CAF authorities. However, any overall sense of risk
management being inconsistent and ad hoc.23
The motivation to establish a formal, comprehensive ERM policy approach focused at the
tactical (NRD) level began in 2016 in response to ongoing issues with accidents during small
boat operations and related mechanical and technical issues. It was observed that lessons learned
were not being shared or understood, and the mounting costs and danger to personnel had
reached the risk tolerance threshold of the Naval Reserve’s leadership.24 In October 2016, the
Naval Reserve Risk Management Working Group was established. Its mandate was to identify
areas of risk and develop processes to promote a risk management culture, with simple tools that
could be used by personnel at the tactical level to improve risk awareness and meet the
21 National Defence, B-GJ-005-502/FP-000 Risk Management for CF Operations (Ottawa: NDHQ, Joint Doctrine Branch, 2007). 22 RCN Command Development Course, EO 001.03 “Risk Management: Applying risk calculus to operational decisions (Victoria, BC: Venture, Naval Officer Training Centre, undated). 23 M.P. Davies, K. Penney, J. Lang, R.C. Campbell, J.I. Crangle, A Grinchteine, D. Garnon, “Naval Reserve Risk Management Working Group Report, NAVRES Risk Management – Changing the Culture” (Quebec City: Naval Reserve Headquarters, 18 December 2017): 3-4. RDIMS 418322 24 Capt(N) M.P. Davies, pers. comm.
8
requirements of higher policy. An important restraint on the working group was that the policy
tools and processes that they developed could not create additional administrative workload.25
The composition of the working group leveraged risk management expertise of Naval
Reserve personnel who practice ERM in their civilian careers. This included the working group
chair who is a vice-president with a major insurance underwriter and working group members
with backgrounds in auditing, project management, law, health policy, environmental health and
safety, and performance management.26 Representation was sought from NRDs across the
country and at different rank levels and military occupations.
Content – Findings and recommendations
The working group conducted reviews of overarching policy, current risk management
processes, and lessons learned. Consultations and briefings were also held with senior leadership
at the national and regional level, and through visits at NRDs. The working group’s report
provided findings and recommendations in the areas of governance, risk management processes,
training and awareness, performance measurement and communications. Key findings included:
Governance:
o Strong governance mechanisms are present, along with established inspections
and audits, oversight and safety management for a variety of high-risk functions.
However, there was no overall risk management structure in the Naval Reserve
aligned with the organization’s mission and tasks, no process to formally identify
25 Commander Naval Reserve, Terms of Reference: Naval Reserve Risk Management Working Group, 6 October 2016. RDIMS 393335. 26 Davies, pers. comm.
9
risks and reduce their impacts, and a lack of consideration of risks and
opportunities from the tactical to the strategic;27
Risk Management Process:
o The Naval Reserve maintained the risk management tools required by higher
authority such as a risk register and upward reporting. However, these
mechanisms did not support the development of strong accountability throughout
the organization – especially awareness and ownership of risk at the tactical and
operational level where much of the risk actually exists.28 Risk management was
very much siloed, with the most robust risk management processes focused
primarily managing financial risk;29
Training and Awareness:
o The process of risk management is not clearly understood, with no formal training
in risk awareness or its incorporation into NRD-level planning and operations.
The result is that there is no risk culture;30 and
There was no system for performance measurement in place, or communications related
to risk management.
The working group’s ultimate conclusion, endorsed by the Commander Naval Reserve, was
that the organization needed “to encourage a culture shift…that is risk aware, and
incorporates principles of risk management across the entire organization.”31
27 Davies et al., NAVRES Risk Management, 2017, 4-6. 28 Ibid., 8-9. 29 Davies, pers. comm. 30 Davies et al., NAVRES Risk Management, 2017: 10. 31 Commander Naval Reserve, “Naval Reserve Risk Management Working Group Implementation Directive,” 19 June 2018. RDIMS 422231.
10
Process – Towards implementation
Canadian ERM expert John Fraser identifies two key processes for the successful
implementation of an ERM policy framework supported by a robust risk culture: conversation
and prioritization.32 Conversation involves engaging actors to build a common understanding of
the key risks to be addressed and the approach to be taken by the ERM policy. These
conversations, which include both context and content, build understanding among the actors and
establish agreed principles and accountabilities.33 Prioritization involves the development of
processes for actors to use risk criteria and tolerances to rank risks based on their likelihood and
severity, decide how those risks will be addressed, and apportion resources accordingly.34
Authors agree that adopting ERM is ultimately a cultural change.35 Implementation of
ERM requires that both conversation and prioritization processes be deliberate and support the
development of an organizational risk culture that fosters awareness of risk, including what the
level of risk tolerance is within the organization, and accountability and ownership of risk and its
management by actors at all levels of the organization. The conversation process is crucial to
facilitating this cultural change. Fraser asserts that conversation processes need to engage
employee actors to build awareness of risk policies without removing accountability for the
managing of risks.36 Building awareness of risk and clearly communicating the levels of risk that
the organization is willing to tolerate must also not discourage appropriate risk taking.37 In a
32 J.R.S. Fraser, “Building Enterprise Risk Management into Agency Processes and Culture,” in Managing Risk Performance: A guide for government decision makers, ed. T.H. Stanton and D.W. Weber (Hoboken, NJ: John Wiley and Sons, 2014): 175. 33 Fraser and Simkins, 2016, 692. 34 T.H. Stanton, “The growing movement for enterprise risk management in government: The United States begin to catch up,” Asia Pacific Journal of Public Administration, 37, 3 (2015): 185. 35 Fraser and Simkins, 2016, 692; D. Brooks, “Creating a Risk-Aware Culture,” in Enterprise Risk Management ed. J. Fraser and B. Simkins (Safari Books, 2010), e-book, 6-2. 36 Fraser 2014, 179. 37 Brooks 2010, 6-5.
11
military setting, this “dynamic risk management” 38 must be calibrated through Commander’s
Intent and supervisors for levels of risk that are considered acceptable for the mission being
undertaken – from introductory training, to regenerative training, to contingency operations.
The working group’s recommendations, summarized in Table 1, emphasized incorporating
a strong risk management framework in the organization to promote a robust risk culture into the
Naval Reserve’s operating culture.
A significant development by the working group was the creation of a Naval Reserve Risk
Management Tool – a Microsoft Excel workbook for the use of NRD personnel and regional
staff in the planning of exercises and activities. Tabbed worksheets guide users through the risk
management, from brainstorming to identify potential risks in a number of categories (Figure 2),
to ranking those risks based on their likelihood and impact (degree of severity) (Figure 3). The
resulting heat map provides a visual appreciation of the assessed risks. Action plans are then
prompted for risks over the tolerance threshold, including four standard risk management
strategies: avoid, accept, mitigate/control or transfer. The resulting aggregate action plan is then
briefed and approved by Command. The signed action plan is appended to administrative or
operations orders as well as being uploaded to a SharePoint site for collection and potentially for
audit and performance measurement. A survey and links to the RCN Lessons Learned Database
and the Naval Reserve Risk Management SharePoint site. The RM Tool satisfies several key
functions. It requires actors to engage in the conversation and prioritization processes, building
awareness of potential risks and how they influence and are influenced by policy content and
context, with that knowledge contributing to risk prioritization and the development of
management and mitigation strategies.
38 Turner, N. and Tennant, S.J. “As far as Reasonably Practicable: Socially Constructing Risk, Safety, and Accidents in Military Operations,” Journal of Business Ethics, Vol. 91, (2009): 26.
12
39 Davies, M.P. et al., NAVRES Risk Management – Changing the Culture, 2.
Table 1. Summary of the Naval Reserve Risk Management Working Group’s recommendations39
1. Governance a. Engrain the risk management framework within the organization b. Formally link risks to the NAVRES vision, mission and tasks c. Clarify the Risk Management organizational structure from tactical to strategic d. Ensure consistent control and oversight external to NAVRES
2. Risk Management Process
a. Strengthen accountability for risks and risk treatment throughout the NAVRES b. Enforce clear lines of responsibility throughout NAVRES for risk analysis, accountability and
reporting c. Enhance the NAVRES risk ledger d. Manage risks on an organizational basis e. Integrate tactical and operational levels into the risk management process
3. Training and Awareness
a. Clarify the risk management process through education and training b. Promote risk smart culture
4. Performance Measurement
a. Continually track and measure the performance of NAVRES risk management efforts
5. Communications a. Provide frequent updates using the established communication tools of the organization
Figure 2. The Naval Reserve Risk Management Tool’s risk identification sheet, including preset risks for a multi-NRD small boat exercise at a third location.
13
Issues
The Risk Management Tool brings the ERM framework and its guiding principles to the
tactical level. It provides an opportunity for NRD commanding officers and their personnel to
consider risks in the tasks they perform, prioritize, and gain appreciations of risk tolerance and
management. Its use incorporates many of the recommended techniques for ERM
implementation,40 including:
Structured conversation;
Integration with planning;
Scenario analysis; and
Sign-off by line management.
Its use, however, must be complemented by a robust, open communications effort that
encourages the raising of issues by personnel at all rank levels.41 Active, ongoing oversight by
leaders at the NRD, regional and national levels must also be exercised, enabled by relevant key
risk indicators and metrics that are not onerous to collect. Most importantly, education in risk
management must be incorporated into training in a way that encourages conversation along the
40 Fraser and Simkins, 2016, 692-695. 41 Brooks 2010, 6-8.
14
Figure 3. The Naval Reserve Risk Management Tool’s risk plotter and heat map.
lines of Fraser’s risk workshop model and avoiding “death by PowerPoint.”
Next Steps
Implementation of the Naval Reserve ERM framework is ongoing, following a plan
endorsed by the Commander Naval Reserves. Significant next steps include the publication of a
distinct tactical-level Naval Reserve ERM policy that is aligned with the strategic policy
framework, making consideration of risks part of deliberations and decision-making at levels of
the institution, ongoing oversight and leadership, and the launch of a concerted communications
15
effort. Since adopting an ERM is a cultural change, continuous effort, ongoing conversations
and patience will be required.
CONCLUSION
Enterprise Risk Management is a systematic, holistic approach to assessing, managing
and mitigating risk across an organization. The Naval Reserve is at the early stages of
implementing an ERM policy at the tactical level that is aligned with the strategic risk
management principles of the RCN, CAF and ultimately the Government of Canada. Through
the application of a policy analysis lens that considers the actors, context, content and process of
the development and implementation to date of the Naval Reserve ERM policy, this bottom-up
approach complements and enables top-down strategic policy while engraining a cultural change
in how Naval Reservists assess and manage risk.
ACKNOWLEDGEMENTS
The assistance and advice of Captain(N) Matthew Davies, Chair of the Naval Reserve
Risk Management Working Group, Working Group members Chief Petty Officer First Class
Robert Campbell and Lieutenant-Commander (retired) Daniel Garnon (Naval Reserve Senior
Staff Officer Inspections and Integrated Risk Management), and Commander J.J. Nadeau (RCN
Directorate of Naval Strategic Management) are gratefully acknowledged.
16
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Canada, Department of National Defence. Defence Enterprise Risk Management Policy.
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